Patricia S. Makalintal - Page 2

                                        - 2 -                                         
                                   Additions to Tax                                   
                    Sec.            Sec.          Sec.                                
               Year   Deficiency   6653(a)(1)(A)   6653(a)(1)(B)     6661             
               1986   $590,852     $29,543             *        $147,713              
               1987    254,088     12,704              *          63,522              
               1988    280,624     14,031**            --          70,156             
                   *  50 percent of interest due on portion of                       
                    underpayment attributable to negligence.                          
               **  For 1988, the applicable addition to tax was                       
                    determined under sec. 6653(a)(1).                                 

               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               After concessions, the issues for decision are whether                 
          Ambrosio G. Makalintal, petitioner’s former husband, and                    
          petitioner underreported their income, and, if so, whether                  
          petitioner qualifies as an innocent spouse under section 6013(e).           


                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               In 1967, Mr. Makalintal and petitioner were married in the             
          Philippines, and until 1985 (when they moved to the United                  
          States), Mr. Makalintal and petitioner were residents and                   
          citizens of the Philippines.  Prior to their divorce in 1990,               
          Mr. Makalintal and petitioner had three children.                           







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